Thursday, 22 March 2012

Save Malaysia Stop Lynas (SMSL) together with the undersigned civil society organizations of Malaysia, would like to strongly implore you as the Malaysian Prime Minister and to immediately suspend the licenseissued to Lynas and to stop any shipment of rare earth ore concentrate into Malaysia.

The Lynas Advanced Materials Plant (LAMP) in Gebeng is the world’s largest rare earth refinery project owned by speculators with no real experience in industrial processing or rare earth. Rare earth refining is linked with serious pollution and health risks. The plant is located in a densely populated area unlike most industrial estates. The closest housing estate is a mere 2km from the plant and within a 30km inland radius live 700,000 people.

The LAMP is the world’s biggest rare earth refinery owned by a lone-project speculative company with no previous experience. Its design is based on the Chinese technology. Yet approval and an operating license were given without due consideration into the full extent of its impact which will only be uncovered through a detailed EIA.

Lynas would not be allowed to construct a plant similar to the LAMP with its associated waste management plan anywhere in Australia. Currently, several other rare earth proposals are being considered in Australia. All of them are committed to adopting a zero-waste water discharge policy and having their radioactive waste returned to the mine site for proper disposal. Clearly, Lynas has not been transparent in claiming that its LAMP project is of international standard.

Specifically we would like to draw your attention to the following facts:

·· Serious construction problems of the LAMP - 22 concrete tanks in the processing area was defective and will result in corrosive and radioactive materials leaking onto the plant floor and into the ground eventually. These tanks were not moisture-proof, which is a standard engineering practice for this kind of plant. It is especially essential in a damp swampy environment. We have and continue to receive confidential accounts of failed electrical wiring and installation, failed hydro tests where major tanks with structural cracks and leaks were detected, broken underground water pipes that need to be redone and so forth. A large section of the plant has sunk. Many of these defects could not be easily fixed or safely repaired. Lynas is believed to have grossed over the problem and have summarily covered up the defects. The full extent of the construction defects and design problems can only be uncovered by a thorough independent engineering audit.

·· The absence of a scientific consensus on what is a safe dose of radiation exposure– There are increasing medical and scientific evidence that prolonged exposure to low-dose radiation is harmful. Lynas has conveniently ignored this risk and the IAEA had grossed over this point without any substantiated reason. The responsible approach under this circumstance is to adopt the precautionary principle of no safe dose and to impose a zero discharge strategy to minimize risks.

·· Lynas will not be able to return the waste to Australia or to a third country. The Western Australian Government has stated TWICE publicly declared it will not accept any of Lynas’ waste from Malaysia – refer to the attached scanned copy of the official statement from the Hansard. At the end of 20 years, Lynas will be dumping 10 million tonnes (wet weight) of solid radioactive waste that will be hazardous for longer than the lifespan of planet earth. This is NOT in Malaysia’s national interest.

·· No safe permanent site for the storage of radioactive waste. The failure of the AELB in managing the radioactive waste from the Asian Rare Earth (ARE) plant in Bukit Merah casts serious doubt that Malaysia has the capacity to safely manage such hazardous waste. Lynas’ solid waste contains many other hazardous substances and heavy metals which should be carefully managed and disposed of. They should NOT be allowed to be commercialized either as gypsum or as a fertiliser.

·· No Detailed Environmental Impact Assessment (EIA) - Serious water contamination by the discharging of 500 tonnes of contaminated water every hour into the important mangrove habitat of the Balok River. Air pollution caused by Lynas’ proposed “air dispersion” technique which is a cheap and unsafe way to disperse the polluting gases into the atmosphere. The refinery plant is located on top of a peatland when cleared is prone to floods and fires. The huge amount of fuel, concentrated acids and other combustible substances which will be kept in the LAMP premises will become fire hazards.

·· Need for a Socio-economic impact study (SIA). - The strong and persistent protest actions against the Lynas project is a clear indication of the threats the project poses to local communities. Our fears are due to the potential loss of a safe environment to live in; potential loss of incomes, and decline in the tourism industry as well as the property market. Furthermore outward migration of families from well-educated and high socio-economic background from Kuantan will lead to a further brain-drain of people who have invested for over a generation and contributed much to the prosperity and development of the town and the state.

·· Lynas’ unrealistic timeline & incompetence. Lynas has promoted an unrealistically early production date for September of 2011 to be the first outside of China to supply rare earth oxides. In truth Lynas has conveniently deceived its investors by attributing the delay to the protests and the licensing delay. The AELB has persistently assisted Lynas by making contradictory public statements both declaring the granting of the licence for the benefit of Lynas just to deny it in another time to appease the angry Malaysian public. Had Lynas admitted to its own failure, its stock would have slipped to a dangerously low value potentially sending Lynas to bankruptcy.

·Economic activities spin off from the LAMP will be limited - Socially responsible and ecologically conscious corporations and investors will not want to associate its operations with or next to a controversial hazardous plant like the LAMP. Decent companies with a clean and green reputation will not risk locating their plants close to the LAMP nor source their supply from Lynas.

·Malaysiarisks gaining a bad reputation as a haven for toxic projects. The massive amount of waste, in particular contaminated air (90,000 cubic metre an hour) and water (500 tonnes an hour), which will be discharged into the natural environment has the potential to contaminate a wider area of coverage thereby posing potential threat to lives in the neighbouring countries. By accepting and facilitating the Lynas project. Malaysia has essentially opened its door to polluting industry escaping tighter scrutiny and carbon tax from industrialised developed countries forced to cut down their carbon pollution from the threat of climate change.

We therefore strongly appeal to you to immediately cancel all LYNAS operations based on the clearly serious life threatening consequences it has on the lives and environment of all peoples in Malaysia.

Radiation around the Asian Rare Earth (ARE) plant in Bukit Merah and its permanent waste dump site at Bukit Kledang, both in Perak, is still at a hazardous level - despite the factory having closed 18 years ago.

The radiation level at the gate of Japan Mitsubishi chemical's Asian Rare Earth plant's radioactive waste permanent depository achieved 0.269micro Sv per hour and we also saw the guards were all day exposed to it.

This disturbing finding was recorded by anti-Lynas group Save Malaysia Stop Lynas (SMSL) during a fact-finding visit to Perak over the weekend.

According to SMSL chairperson Tan Bun Teet (right), SMSL members armed with radiation reading devices were not allowed to enter the plant and dump site, but the radiation readings around both locations showed worrying results.

The reading near the plant was around 0.19 microsievert per hour while the reading near the dump site stood at about 0.2 microsievert per hour.

Both readings, if extrapolated to annual basis, are beyond the safe level of 1 milisievert per year as advised by the Atomic Energy Licensing Board (AELB), Tan said.

The average background reading of Malaysia is 0.05 microsievert per hour.

“It is regrettable that within the 1.7km buffer zone of the dump site, we still found fish breeding, as well as animal and vegetable farming activities (left),” Tan said.

AELB had earlier claimed that the plant site has been decontaminated, with radiation levels dropping from 0.65 microsievert per hour to 0.17 microsievert per hour, which is safe for human activities.

The board also claimed that it had requested the authorities to move illegal farms and squatters living within the buffer zone around the waste dump site.

The ARE plant run by Japanese company Mitsubishi Chemicals from the 1980s to the early 1990s, is blamed for spreading radiation poisoning inas a result of poor management of radioactive waste generated from processing tin tailings to extract rare earth.

The aftermath of the factory’s operations has been one of the largest radioactive waste clean-ups in Asia, with a permanent dumping site set up at the foot of nearby Bukit Kledang.

The anti-Lynas movement has been using the ARE plant as an example to protest against the Lynas rare earths plant in Gebeng, Kuantan.

Members of SMSL also met with a former contractor who was hired by ARE to dump the radioactive waste.

According to Tan, the contractor, whose three employees carrying out the job have died at a young age.

The contractor said they just discarded the waste into empty plots of land within Menglembu and Lahat as ARE had not specified a dump site.

In other words, the polluted areas are larger than what the authorities had expected, and they are difficult to trace, Tan elaborated.

Tan is also disappointed with the Ipoh Hospital which, he said, did not trace the backgrounds of cancer patients over the years to determine whether they were from the affected areas.

This matter was conveyed to Tan by Dr Chan Chee Khoon, an epidemiologist from Universiti Malaya, who has been following the issue and has had discussions with the medical personnel of Ipoh Hospital.

“This shows that the government did not follow up on the health conditions of residents in that area,” added Tan.

Monday, 12 March 2012

Residents from Sg Lembing near Kuantan, Pahang, staged a protest today to express outrage against the proposal to dump radioactive waste in a disused mine shaft in their town.

Braving the morning drizzle, some 300 of them accompanied by members of the Save Malaysia Stop Lynas (SMSL) group gathered at their town’s morning market at 8am, bearing placards and shouting slogans such as ‘Hancur Lynas, hidup rakyat’ (Destroy Lynas, long live the people), ‘Stop Lynas, save Malaysia’.

The protest takes place just a day after Pahang MB Adnan Yaakob blasted Chinese newspaper journalists as “stupid” for reporting his statement on the issue.

SMSL said the locals fear that the proposal will ruin the town’s economy and newly-established tourism industry.

The former mining town some 40km northwest of Kuantan has suffered years of decline since mining activities ceased in the 1980s. The situation has recently only improved through weekend tourism.

In a phone interview after the rally, Kuantan MP Fuziah Salleh (right) said she told the protesters in her speech that the government has got their mind wrong, in zoning Sg Lembing as potential dump site due to the town’s mining history.

“The government say (Sg Lembing’s) former mine tailings (monazite) have a radioactivity of 20bq/gram, which is higher than that of the Lynas waste,”

“If that is the case, what they need to do is to clean up the mine waste, not put Lynas’ waste into it,” said Fuziah, a key figure in the anti-Lynas movement.

Citizen paying the price

During this morning’s protest, SMSL vice chairperson Ismail Abdul Bakar warned that locals could have their livelihoods affected if the dump site destroys their environment.

“The transportation of huge amount of radioactive waste through the highway, passing kampungs and towns will further spread Lynas’ toxic waste around,” he said.

“It is unacceptable and totally unjust to expect ordinary citizens to pay such a high price while a foreign company gets to pollute our rivers, our seas and now our water supply and community tourism – all tax free!” he said.

He added that Sg Lembing was a water catchment area for Kuantan, and its ground water owing to the region’s limestone geology risks being contaminated by the radioactive waste dump.

“How many more communities will the government destroy for the sake of helping a foreign company profit from an unsafe rare earth plant?” asked Ismail.

Towards the end of the protest, Fuziah led the crowd to visit a nearby disused mine shaft, to show them how discarded mine tailings packed in bags had been left unattended by the previous miners and can contaminate the surroundings.

“Some of the bags are now broken, and tailings have leaked into the stream which in turn goes into the rivers,” she explained.

Sunday, 11 March 2012

【Nanyang press March 08, 2012】: STG group chairman Datuk Dr Alex Tan Siong Sengdeclared to give up the 30million (latest in Ringgit Malaysia) investment in the new development project - Goal Coast Kuantan Resort which is now under construction at Jalan Beserah, Kuantan if Lynas Malaysia rare earth refinery which is under construction also at Gebeng allowed to operate.

According to him, about 30% of its customers had given up the deposit so far.

He claimed that he would rather lose the RM 3million than the whole! His project can create 500 to 600 working opportunities which 70% of it will be for the local residents compared to Lynas' 300 only.

Saturday, 10 March 2012

The committee members of Himpunan Hijau 2.0 handed letter to Singapore High Commission

With regards to above matter, we, a group of concerned residents from Kuantan, appreciate the opportunity given to us to bring to your attention the potential health and environmental risk of the Lynas Advanced Materials Plant (LAMP) in Gebeng, Kuantan to the surrounding areas including neighbouring ASEAN countries.

For the sake of brevity, we shall summarize the potential effects on Singapore in this text, and some of the justification of our assessment in the appendix.

The Lynas Advanced Materials Plant (known as “LAMP” herein) will commence its operation to process enriched rare earth ore (known as concentrates herein) and yield high purity rare earth oxides. The rare earth mineral will be mined at Mount Weld, Western Australia and subsequently enriched onsite prior to trucking to Port of Fremantle, 1000 km away. The concentrates will be loaded into the 20-feet containers and commenced a 4000 km sea voyage to Singapore, where c.a. 4000 containers/year will be unloaded to smaller vessels prior to heading to the Port of Kuantan. The intended load to LAMP is approximately 65,000 tonnes/year (dry base); 80,000 tonnes/year (wet base). The rare earth oxides are inherently harmless, however, two elements bound with the rare earth to form the ore, are radioactive, i.e. thorium and uranium.

The LAMP processes require substantial amount of chemicals and reagents, such as sulphuric acid, magnesium oxide, hydrochloric acid and utilities such as raw water and natural gas. These are required to extract the rare earth oxides and to generate copious amount of wastes including three types of gypsum, i.e. Flue Gas Desulphurisation (FGD), Water Leach Purification (WLP) and Neutralization Underflow (NUF) residues, flue gas and waste water. In other words, operations cannot start and continue without the creation of waste.

It is the intention of Lynas to “purge” almost all radioactive materials (thorium and uranium) and to channel them to a sole waste stream, known as WLP. The radioactivity concentration in the other 4 waste streams is regarded as either non-detectable or negligible. The table next page summarizes the characteristics of each waste stream:

WLP residue 64,000 tons/year Total activity 62.3 Bq/g Commercialized as road building material, failing which it will need to be permanently isolated

The commercialization of the wastes is still in the R&D stage. There is no indication that there are any interested buyers for these recycled products. Even if there is, there are serious implications of such disposal methods, as products containing trace amounts of radioactive elements will be sold throughout Malaysia, and possibly Singapore.

Lynas intends to commence operation while figuring out what to do with the waste. In the meantime, they will store the solid residues on-site in open storage ponds, as they have not yet identified the Permanent Disposal Facility (PDF) where the radioactive wastes are to be buried.

We are very concerned that LAMP poses real risk of contamination because:
1) the site of the plant is on a reclaimed swamp land, and the underground water table is merely 0.95 – 3.5 m below surface.
2) the low-lying area is prone to flooding due to the monsoon rain.
3) the New York Times reported serious construction and design flaws that “have the potential to cause the plants critical failure in operation” [1,2].
4) the half-life of the primary source of radioactivity, i.e. thorium-232 is 14 billion years. This may result in the accumulation of radioactivity over time from “negligible” sources

We feel, therefore, that the LAMP will bring serious repercussions to the people of Malaysia and Singapore. It may affect Singapore via these scenarios:

a) Food security

Kuantan is a major seafood producer with 390 registered deep sea trawlers. Significant seafood caught in Kuantan ends up in Singapore. Radiation risk may spread across border through radioactivity accumulated in the food chain.

b) Other sources of contamination

Other pathways may come from products that are made with contaminated materials, for example, palm oil, birds nest, fruits and vegetables, as well as Lynas’ proposed products that are made with their wastes. The US found out the consequences of using gypsum board made with FGD-type residue, and had in 1989 banned the use of this product. Also, the US EPA also noted that the use of fertilizers made with NUF-type residue can increase the radioactivity of the produce [3]. Lynas must not be allowed to spread their pollution.

c) Risk from transporting the raw material through Singapore

According to the RIA, 65,000 tons per annum will go through Singapore in 4000 containers annually. Lynas has disclosed that the payload will be sealed inside double layered plastic bags. It will be transported as non-radioactive but as soon as it touches down in Kuantan, it is classified as radioactive. This is due to a legal loophole in Australia’s Dangerous Goods Act. The construction of the bags are not known. We do not know how robust they are. A spill may be disastrous to the environment.

d) Deterrent to Malaysia’s nuclear ambition

Due to its size, Singapore will probably not pursue nuclear power due to these power plants becoming strategic targets in times of war. This leads to Singapore being unfairly subjected to radiation risk from its neighbors’ nuclear ambitions. If Lynas is allowed to proceed, and the Malaysian public buy the “radiation safety” propaganda, nuclear plants will be next in line. If we stop Lynas now, the government will not dare to proceed to nuclear plants due to the political risks. Malaysia is capable of harnessing renewable energies and Malaysia’s wet climate is not suitable for nuclear repositories according to IAEA’s guideline [4] . The people of Malaysia and Singapore don’t need any more radiation risk and it is in Singapore’s interest that the Malaysian public remains averse to it.

Finally on 1/3/2012, a few days after the 15,000 strong green rally against Lynas, a Singaporean academia Professor ??? expressed doubt over the safety of the plant [5]. Given Malaysia’s poor record in construction reliability, the most memorable one is the collapse of the roof of a newly constructed stadium in Terengganu, nobody trusts the incompetent Malaysia government to manage such a high risk venture.

We hope that the Singapore government agrees that the Lynas project is a reckless industrial experiment, and we hope that your honorable commissioner can do everything within your diplomatic power to persuade the Malaysian government to abandon this project.

All regulatory scrutinises are qualified based on data provided by Lynas. Unfortunately, Lynas has not had any prior experience operating such a project. Nor does Lynas possess a pilot-scale plant which would generate an industries-proven data to corroborate claims. Therefore, the proposition by Lynas can be wholly disputed.

LAMP recently invited 4 members of the public and 3 local media reporters for an onsite visit/interview. During this visit Lynas admitted that most of the process data presented by it in the public domain have been obtained from results which have emerged by process simulation and laboratory analysis [6]. It must be kept in mind that “Process simulation” is used for the design, development, analysis, and optimization of technical processes and is mainly applied to chemical plants and chemical processes. When this computational process model/simulation is built, some phenomena are simplified, and consequently some parameters are disregarded or distorted in comparison with reality. In addition, some of the relationships between the parameters could be neglected. [ref: Tanase Gh. Dobre, José G. Sanchez Marcano. “Chemical Engineering: Modelling, Simulation and Similitude”. John Wiley & Sons. pp 20. 2007].

What is far more valuable and far more accurate is actual data from real experience. Thus, if Lynas has actually been in this business they could have supplied real facts. Alternatively, Lynas could have provided the actual results from the Chinese experience. (To date, China is the world’s sole rare earth producer)

b) The radiation risk is greater than what Lynas and the Malaysian government are willing to admit

The radiation safety aspect of LAMP is legitimize by the IAEA’s review. However, increasing number of scientific literature points to a strong possibility that the IAEA model may have underestimated the risk of internal emitters, which are radioactive sources that are inhaled or ingested. This hypothesis is not merely based on correlation type studies, but is backed with sound scientific reasoning.

Thorium accumulates in the body. According to the “Radiological and Chemical Fact Sheets to Support Health Risk Analyses for Contamination”, about 0.02% to 0.05% of ingested thorium is dissolved in the bloodstream, and subsequently deposited mainly in the bones where the radioactive source becomes embedded within the bone tissue for a few decades . We are unsure exactly how much the body retains thorium from inhalation, but we know that “thorium is taken up in the body much more readily if inhaled rather than ingested”. True enough, the Radiological Risk Coefficient from inhalation is 450 times greater than that of ingestion [7].

Therefore if significant embedment of thorium is expected, the competing theory against IAEA’s ICRP model, the ECRR (European Committee on Radiation Risk) model must be considered because it takes into account the effects of thorium retention in the body. ECRR proponents reasonably believe that the ICRP formulation is wrong to dilute the radiation exposure from internal sources to the whole body, instead of confining it to the surrounding tissue only. So, the ECRR contends that the ICRP model has underestimated the real risk of low-level radiation.

In an email exchange between Lynas’ Radiological Safety Officer Nick Tsurikov and the editor for ECRR Chris Busby, Chris Busby suggested that the risk from internal thorium exposure should be 100 times greater than what IAEA says it is [8]. The fact is, there is much uncertainty over the actual risk of low-level radiation within the scientific community. It is foolish for the Malaysian government to ignore the possibility that the ECRR might be right.

c) Effects to food chain

A serious contamination will cause the accumulation of radioactivity in the food chain.

Amazingly, Lynas agrees with us! According to their Radiological Impact Assessment (RIA), they computed through their radiation model that in 1558 years [9], the public exposure from drinking contaminated water and eating contaminated fish can reach 6.23 mSv/year, 6 times the allowable limit of 1 mSv/year, which we believe is an understatement because it is derived using the ICRP model. Thorium contaminated fish is not differentiable, it will not be easy to boycott fish the same way a recognizable product can be boycotted.

d) Construction reliability

New York Times on the 29th June 2011 in the article “The Fear of a Toxic Rerun” revealed cost-cutting practices as well as construction and design flaws of the plant. Some of them are “structural cracks, air pockets and leaks in many of the concrete shells for 70 containment tanks.” Then on 31st January 2012 in the article “Rare Earth Metal Refinery Nears Approval” reported that one of the key contractors to Lynas, AkzNobel pulled out due to quality concerns.

In response to these allegations, the Malaysian government tried half-heartedly to appease the public’s concern by obtaining safety verification from an unidentified registered engineer. No further information was given on the certification process [10]. So, in addition to the uncertainty over the real risk from low-level radiation, we now also face the uncertainty over the impermeability of their waste ponds.

e) How rare earth processing should have been done

Lynas loves to boast that their project is approved in Australia also. Given Australia’s high environmental standard, if it is approved in Australia, why would Malaysians reject it? However, Lynas hid from the public that the Australian proposal was approved under extremely stringent conditions.

The table next page shows the conditions under the Australian proposal compared to LAMP.

Australia
Bury the waste at Mt Weld where it came from. No accumulation of waste at the refinery, the waste is shipped to the burial site immediately as they are produced.
Malaysian
No permanent waste disposal plan. Temporarily dump on-site.

Australia
To and from land transport between Mt Weld and the refinery site at Meenaar, 880 km apart.
Malaysia
Raw materials transported 1000 km by land and more than 4000 km by sea to Gebeng.

Australia
Nearest population center is 35 km away, with only 1,500 inhabitants.
Malaysia
700,000 people living within 35 km.